Document ba5XgK4qY3y4zNJJmeDaQOR7O
V PLAINTIFF'S EXHIBIT
UNION CARBIDE CORPORATION SILICONES AND URETHANE INTERMEDIATES
Engineering South Charleston, West Virginia
MEMORANDUM
February 11, 1985
TO: ' W. E. Ballard J. A. Bowyer
JEBBBHSfET
C. R. Gillespie J. G. Roy
T. G. Swanson P. G. West
COPY TO: J. F. Dodd
FROM:
W. L. Thomas
SUBJECT: Asbestos Insulation Replacement Protect - Phase I
Please attend a meeting on Thursday, February 21, 1985 In Building B2-320 at 1:30 p.m. to plan this project. It Is proposed that discussions center around the following:
Select a scope that satisfies the $900H cash flow objective for 1985.
Ascertain who does what work. Develop an action plan for WOR submittal by March 31, 1985.
Attached for your advance reading Is a proposal by Jerry Roy.
WLT:JJv Attachment 48950
W. L. Thomas
UCC 003129
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UNION CARBIDE CORPORATION
P. O. BOX 8004, SOUTH CHARLESTON. W. VA. 25303 Silicones end Urethane Intermediates South Charleston Plant
To: * ; Mr. T. G. Swanson
Copy to:
Mr. W. E. Ballard Mr. J. R. Dean Mr. C. E. Fry Mr. D. G. Moshier Mr. R. A. Ream
ES Routing- List 2
From: Date:
J. G. Roy
;
December 27, 1984
Subject: No. 2 Steam Plant Asbestos Insulation Replacement
*ECi:,V<S
JAN - seas
Offj.
One of my MOP's for the 4th Quarter is the development of a program to phase out asbestos from the steam plant. I understood from Bob Ream at the time I was given the assigment that special budget provisions were being made to kick this off in 1985. ` This apparently came about during budget presentations to SUI division management.
Attached is my proposal to accomplish the overall objectives. I've not attempted to quantify the project into monetary blocks (Bob indicated that guideline established was $250,000 expenditure per year) but have presented it in pieces as a control measure. I believe the approach outlined will provide the greatest return both from a health and economic standpoint.
By copy to the department staff I would appreciate their re view of both the approach and the individual work list. The most successful projects are those with the most thorough and up front work.
JCRrkab Attachments
J. G. Roy UCC 003130
ASBESTOS ELIMINATION PROGRAM
Building 151
General; As an energy conversion facility constructed in large part
during Its first twenty years (1933-1953), the No. 2 Steam Plant
insulation was originally all asbestos. While rebuilds of pre cipitators and 25 Boiler together with SCESUP additions incorporated non-asbestos materials the majority of the insulation is still asbestos. In reviewing the health related issues involved in steam plant operation asbestos exposure has to be viewed as one of the critical few.
There are several approaches which can be taken to the resolu tion of this problem. One is to continue the phasing out of asbes tos by attrition i.e. repairs with non-asbestos material. Asbestos can also be rendered harmless by sealing the surface to prevent fiber migration into the atmosphere. The ultimate solution is a total replacement of all asbestos material.
The program outlined in this proposal is aimed at elimination rather than control. Realizing that the project cannot be accomplished overnight so to speak, a phased approach incorporating discrete pieces of work (shown on attached listing) is recommended to proceed in the following manner. Schedule/Funding
The precautions and health monitoring required for asbestos re lated work is very intensive in comparison to other types of work. For this reason it's important that specific task be started and completed in a timely fashion. Full replacement of all asbestos
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has been roughly estimated to be in excess of one million dollars.
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The magnitude of the project almost dictates a phased approach not only from the monetary standpoint but to avoid chaos in the normal operation and maintenance activities. For this reason the attached list of work has been arranged in a quasi prioritized order. You will note that the first part deals with the removal only require ments. This of course offers the greatest return on expenditure. The remaining individual items are arranged to make significant contributions with emphasis on places where exposure is most likely. For instance the last item is the 25 Boiler feed water lines. These were fairly well sealed during SCESUP. Also work around the turbine generators should coincide with the scheduled ovethaul of these machines.
Funding is visualized at a rate of 150-250M$ pwer year and be comes a budgeted item until the project is completed. I believe that the distribution of work outlined below will produce a high level of efficiency to keep the overall cost well below the original estimate. Work Assignments
There's plenty of work for everyone I However keeping in mind the need for timely execution coupled with costs, the project seg ments can be best accomplished by various groups. I visualize the use of demolition contractors, insulation contractors, and UCC Construction as well as Plant Maintenance. Each of these work groups offers unique skills that can expedite as well as minimize the costs for various pieces of the project. Demolition Contractors: These people are geared to removal work
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and can strip idle facilities very quickly at reasonable costs. Insulation Contractors: Traditionally, UCC insulation projects have been overdone in the sense that we do a better job than is needed. Of course our costs are higher as a result. We almost universally use the block and wire approach with fabric coatings on large flat 6urfaqes when other systems such as mineral wool on impaling wires and metal lagging are much more prevelent in the industry. Con tractors having to meet stiff competition have developed systems that are sufficiently sturdy but minimize both material cost and labor. A case in point is the system we bought from Riley Stoker for the No. 25 Boiler rebuild. This project scoffed at by a number of construction people at the time, appeared to be flimsy. The entire Insulation and lagging is supported on the impaling wires with no use of stand-offs and angle iron frames to mount the metal lagging. The bottom line is that it works and the cost is lower. For this reason I recommend that major equipment such as boiler ducts and breechings be insulated by contractors. UCC Construction: For the most part it will be virtually impossible to isolate steam and hot boiler feed water headers for stripping and reinsulation. From a health, safety and economic standpoint, it is important that long segments of header be stripped with re-, insulation following closely. Construction's manpower availability is suited to this kind of activity. Maintenance: There is a definite need to address miscellaneous lines and equipment that while limited in scope are more time con suming. The nature of work it lends itself to an intermittent pro gression of this type of work and should aid in the overall plant
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scheduling of this manpower short craft.
The following is a suggested assignment of the attached items
to the various resources described above.
Demolition Contractors - 1 through 10
Insulation Contractors - 11 through 18
UCC Construction
- 19 through 37
514 Maintenance
- 38 through 49
Project Control
Unless tight control is exercised for a project of this type
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monies have a way of being spent without a whole lot to show for it.
It is important that all changes accrue to a single account and be
reviewed on a monthly basis. Additionally a file must be maintained
to measure progress of the overall effort.
^ome, time ago a program was undertaken to identify all asbestos
with stickers. I understand that stickers were placed on just about
every insulated surface and I've heard insulators say that many non
asbestos surfaces were eroneously labeled. Also due to dirt con
ditions many stickers failed to stay in place.
Perhaps a more effective way to start the project would be to
identify all of the insulation that is non-asbestos. There has
been a lot of insulating done since 1972 and with our knowledge of
project timing etc. it should not be difficult to pin down the
majority of non-asbestos material. Identification with a stencil
and spray paint would be a good first step leading into the overall
project.
UCC 003134
ASBESTOS ELIMINATION PROGRAM
Building 151
Removal From Idle Factilities 1. No. 14 I.D. fan and breeching to the south stack2. Nos. 12 and 13 precipitator hoppers 3. No. 12 l.D. fan 4. No. 14 Boiler air ducts, drum heads, feed water lines, and
steam header to the main header isolation valve 5. No. 12 precipitator inlet breeching and duct
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6. No. 12 Boiler air heater, ducts, feed water lines, drum heads, and steam header to the isolation valve at the main header
7. No. 12 bubar ash collector 8. No. 12 pulverizer coal ducts from feeders 9. No. 13 pulverizer coal ducts from feeders 10. No. 13 hot air ducts to the coal feeders Remove and Replace With Non-Asbestos 11. South stack breeching serving Boilers 15 and 16 12. No. 15 l.D. fan and precipitator hoppers 13. No. 16 l.D. fan and precipitator hoppers 14. No. 16 precipitator inlet breeching 15. No. 16 Boiler air heater, ducts, drum beads, feed water piping,
boiler headers and steam header to isolation valve at the main header 16. No. 15 Boiler, air heater, air ducts, drum heads, feed water piping, boiler headers and steam header to isolation valve at main header 17. No. 15 precipitator inlet breeching 18. No. 13 Boiler air heater, air ducts, feed water piping, drum heads, and steam header to the isolation valve at the main header
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Remove and Replace With Non-Asbestos (Continued) 19. No. 25 atmosphericflash tank 20. No. 25 deaerator 21. No. 25 high pressureheater
22. South end 10 psi flash tank and associated headers
23. No. 3 deaerator 24. 200 psi flash tank and headers
25. 10 psi steam header from north end to No. 3 deaerator, south end feed water pumps and on to the 200-10 psi reducer; section behind 14 Boiler is OK \V
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26. No. 2 deaerator and headers on that level 27. North 600-200 psi (Hagen) reducing station and all steam
headers in that area 28. All deaerated boiler water lines below No. 2 deaerator on
operating level 29. North end 200-10 psi reducing station and associated headers
30. South end blowdown recovery heat exchanger and associated piping
31. South end high pressure feed water heater and associated piping 32. All steam and feed water piping associated with Nos. 4 and 5
boiler feed water pumps 33. Ducts between the coal feeders and pulverizers serving Boilers
15 and 16. 34. Boiler feedwater headers serving all boilers 35. Main 200 and 600 psig headers through basement
36. West process steam header 37. North end boiler feedwater pump steam and water lines 38. Atmospheric flash tank and associated piping at No. 8 turbine
generator 39. No. 8 turbine generator inlet and exhaust steam headers 40. All remaining miscellaneous lines and equipment at the basement
level
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Remove and Replace With Non-Asbestos (Continued) 41. All remaining miscellaneous lines and equipment on the operat
ing level 42. All remaining miscellaneous lines and equipment at the 3rd
level 43. All remaining miscellaneous lines and equipment at the 4th
level 44. All remaining miscellaneous lines and equipment in the bunker
and east roof level 45. All remaining miscellaneous lines and equipment on the main
precipitator platform 46. All remaining miscellaneous lines and equipment on the 25
precipitator platform and l.D. fan area 47. Steam header serving 25 high pressure heater and all water
piping associated with both the high pressure heater and the deaerator 48. All remaining miscellaneous lines and equipment in the struc ture located on the north side of 25 Boiler 49. All water lines and miscellaneous steam tracer supply headers in the north yard area and around the north residue manifold
JGRoyrkab 12/28/84
UCC 003137